ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN...
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ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 1
ANTI-FRAUD AND CORRUPTION STRATEGY AND
PREVENTION PLAN
2013/14 Financial Year
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TABLE OF CONTENTS
CONTENTS PAGE
1. Summary 3-4
2. Objective 4
3. Legislative Requirements 5
4. Scope 6
5. Strategy Statements 6
6. Fraud and Corruption Strategies 6
6.1 Structural Strategies 6-7
6.2 Operational Strategies 8-13
6.3 Detection Strategies 13-16
6.4 Internal Control Review and Analysis 16-17
7. Response Strategies 17-18
8. Maintenance Strategies 18
9. Resolutions 18-20
10. Oversight Structures 20
11. Fraud and Corruption case database 20
12. Application of the Prevention Controls and Detective Mechanism 20
13. Monitoring and Review 20-21
14. Specific Provisions 21
15 Administration 21
16. Glossary of terms 22-23
17. Addendum 23-26
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1. Summary
Fraud and corruption is a global phenomenon and as such require concerted efforts from
both the public and private sector. //Khara Hais Municipality recognises four components i.e.
prevention, detection, investigation and resolution, which plays an integral part in the fight
against fraud and corruption.
The primary objective of this strategy is to prevent fraudulent conduct before it occurs. The
fundamental advantage of prevention of fraudulent conduct advances two main purpose of
criminal law: deterring future criminal conduct and protecting the public from dangerous
offenders. The characteristic of successful fraud enforcement is its effectiveness not only in
apprehending those who have already violated the law, but also in preventing others from
committing acts of fraud. In South Africa, Common Law defines fraud as “the unlawful and
intentional making of a misrepresentation which causes actual and or potential prejudice to
another”.
The term “fraud” is also used in a wider sense by the general public. In this regard, the term
is used in this document in its widest possible meaning and is intended to include all aspects
of economic crime and acts of dishonesty. In other words, fraud can be described as any
conduct or behaviour of which a dishonest representation and/or appropriation forms an
element.
The general offence of corruption is contained in Section 3 of The Prevention and
Combating of Corrupt Activities Act. This section provides that any person who gives or
accepts or agrees or offers to accept / receive any gratification from another person in order
to influence such other person in a manner that amounts to:
The illegal or unauthorised performance of such other person’s powers, duties or
functions;
An abuse of authority, a breach of trust, or the violation of a legal duty or a set of rules;
The achievement of an unjustified result; or
Any other unauthorised or improper inducement to do or not to do anything is guilty of the
offence of Corruption.
Corruption in its wider meaning, and as referred to in this document, includes any conduct or
behaviour where a person accepts, agrees or offers any gratification for him/her or for
another person where the purpose is to act dishonestly or illegally. Such behaviour also
includes the misuse of material or information, abuse of a position of authority or a breach of
trust or violation of duty.
1.1 Linkage with other National Anti-Corruption Strategies
1.1.1 The Public Service Anti-Corruption Strategy
During 1997, Government initiated a National Anti-Corruption campaign. This campaign
progressed to a National Anti-Corruption Summit held in April 1999 at which all sectors of
society (public and private) committed themselves to establishing sectorial anti-corruption
strategies. At the same time, they also committed to the co-responsibility for fighting
corruption through the coordination of these sectorial strategies.
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A range of other resolutions emanated from this Summit and all the sectors committed to
implementing these.
The Department of Public Service and Administration (DPSA) was instructed to forge various
initiatives across the public service into a coherent strategy with the support of other
Departments. A Public Service Task Team (PSTT) consisting of key Departments was
convened for this task and representation from local government and public entities were
included in order to establish a platform for the roll-out of the strategy to the whole of the
Public Sector (Public Service, Local Government and Public Entities).
1.1.2 The Local Government Anti-Corruption Strategy
Local Government developed the Local Government Anti-Corruption Strategy (LGACS),
which is modelled around the Public Service Anti-Corruption Strategy. The main principles
upon which the LGACS is based are the following:
Creating a culture within municipalities, that is intolerant to unethical conduct, fraud and
corruption;
Strengthening community participation in the fight against corruption in municipalities;
Strengthening relationships, with key stakeholders, that are necessary to support the
actions required to fight corruption in municipalities, for example, South African Local
Government Association (SALGA), Employee Representative Unions, and Communities;
Deterring and preventing of unethical conduct, fraud and corruption;
Detecting and investigating unethical conduct, fraud and corruption;
Taking appropriate action in the event of irregularities, for example, disciplinary action,
recovery of losses, prosecution, etc; and
Applying sanctions, which include redress in respect of financial losses.
1.2 Components of the plan
The main principles of the Fraud Prevention are the following -
Creating a culture which is intolerable to corruption / fraud
Deterrence of corruption and fraud
Preventing corruption/fraud which cannot be deterred
Detection of corruption/fraud
Fraud prevention plan/strategy
Investigating detected corruption/fraud
Taking appropriate action against fraudsters. e.g. prosecution, disciplinary action
Applying sanctions, which include redress in respect of financial losses
2. Objective
Encourage a culture within //Khara Hais Municipality where all employees, the public and
other stakeholders continuously behave ethically in their dealings with, or on behalf of
//Khara Hais Municipality improving accountability, efficiency and effective administration
within //Khara Hais Municipality. Improving the application of systems, policies, procedures
and regulations, changing processes of the Municipality that facilitate corruption/fraud and
allow it to go unnoticed or unreported.
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3. Legislative requirements
3.1 Municipal Finance Management Act no. 56 of 2003
Section 62 of the MFMA
“Accounting authority of the municipality must ensure that it has and maintains effective,
efficient and transparent systems of financial management, internal control and risk
management.”
Treasury Regulation 27.2.1 extends the above requirement with emphasis on Risk
Assessment, Risk Management Strategy and Fraud Prevention Plan summarized as follows:
I. The Accounting Authority must ensure that a risk assessment is conducted regularly
to identify emerging risk of the institution.
II. A risk management strategy, which must include a fraud prevention plan, must be
used to direct internal audit effort and priority and to determine the skills required of
managers and staff to improve controls and to manage these risks.
III. The strategy must be clearly communicated to all officials to ensure that the risk
management strategy is incorporated into the language and culture of the institution.
3.2 Protected disclosure Act. No 26 of 2000
Protects employees who disclose information on fraudulent activities against victimization.
3.3 The King III Report
Code of Governance reflects on integrated reporting as an increase in the organisation’s
business opportunities and an improvement in risk management. The principles outlined on
the code of governance requires that:- the risk tolerance level should be determined by top
management; the risk or audit committee to assist management on carrying out the risk
responsibilities; management to design, implement and monitor the risk management plan;
risk assessment to be conducted on a continuous basis; framework and methodologies are
implemented to increase the profitability of anticipating unpredictable risks; management
considers and implements appropriate risk responses; there is continuous risk monitoring by
management; assurance given to management regarding the effectiveness of risk
management process.
3.4Other related legislative requirements;
The Constitution of the Republic of South Africa, (Act No. 108 of 1996)
Local Government: Municipal Systems Act, (No. 32 of 2000)
Local Government: Municipal Structures Act, (No. 117 of 1998)
Local Government: Municipal Supply Chain Management Regulations, (Act No 27636 of 2005)
Prevention of Organised Crime Act 121 of 1998
The Prevention and Combating of Corrupt Activities Act 12 of 2004
Public Service Act, 1994
The National Prosecuting Authority Amendment Act,2000
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National Strategic Intelligence Act, 1994
Strategic Intelligence Amendment Act, 2002 (67 of 2002)
Fraud prevention plan/strategy
4. Scope
This strategy, plan and policy applies to all corruption, fraud, theft and maladministration or suspected irregularities of this nature involving, but not limited to, the following persons or entities: a) Employees of the Municipality; b) Political Office Bearers; c) Councillors; d) Consultants, suppliers, contractors and other providers of goods and services to the
Municipality. 5. Strategy Statement
This Anti-Corruption Strategy and Fraud Prevention Plan are being developed as a result of
the expressed commitment of Government to fight corruption. It is also an important
contribution to the National Anti-Corruption Strategy of the country and supplements both the
Public Service Anti-Corruption Strategy and the Local Government Anti-Corruption Strategy
as outlined in paragraph 1.4 below. The Strategy aims to emphasise a structured approach
to the effective management of fraud and corruption within the Municipality. Fraud
represents a significant potential risk to the Department’s assets, service delivery and
reputation. Fraud prevention and detection strategies will be designed and implemented.
These will include any existing controls (systems & manual internal controls) and those
currently prescribed in existing policies, procedures and other relevant prescripts to the
activities of //Khara Hais Municipality. The Municipality will not tolerate any corrupt or
fraudulent activities, whether internal or external, and will strongly pursue and initiate the
prosecution of any parties which are involved/ engaged in such practices or attempt to do so.
6. Fraud and corruption control Strategies
The approach in controlling fraud and corruption is focused on 3 areas, namely;
Structural strategies (Oversight Structures)
Operational Strategies
Maintenance Strategies
6.1 Structural Strategies
Represents the actions to be undertaken in order to address Fraud and Corruption at the
structural level.
6.1.1. Management accountability
The Municipal Manager as the Accounting Officer bears the ultimate responsibility for fraud
and corruption risk management within the Municipality. This includes the coordination of
risk assessments, overseeing the investigation of suspected fraud and corruption, and
facilitation for the reporting of such instances.
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Managers and supervisors have oversight responsibility for internal controls within their
units. The implementation of controls should/could be included in performance agreements
of managers at all levels. The latter will lead to increased focus in mitigating risks and teach
a risk management culture. The day to day responsibilities for the prevention and detection
of fraud rest with line managers who are responsible for identifying the risks to which
systems, operations and procedures are exposed
Developing and maintaining effective controls to prevent and detect fraud and ensuring that
controls are being complied with. Failure to take remedial measures to correct an irregularity
in the systems or internal control will lead to the Municipality taking disciplinary measures
against the responsible manager in the unit concerned. The Internal Audit and Risk
Management Unit have no primary responsibility for establishing or maintaining internal
controls. However, the effectiveness of the internal controls are enhanced through the
reviews performed and recommendations made by both sections. Managers should ensure
that recommendations made by Internal Audit and any other assurance providers are fully
implemented within a specified time.
6.1.2. Ethical Culture
Ethics are concerned with human character and conduct and deal with questions of right and
wrong, appropriate and inappropriate behaviour and what constitute good or evil. The ethical
principles contained in the Code of Conduct for the Public Service are applicable to all
employees of the Municipality. Therefore, the Code of Conduct for the Public Service as set
out by the Public Service Commission will be customised accordingly towards the core
business operations of the Municipality. All employees are expected to abide by the code of
conduct. The municipality is required to conduct itself in an ethical and moral way.
Senior management of //Khara Hais Municipality are committed to eradicating fraud and
corruption and ensuring that the municipality strives to be perceived as ethical in all its
dealings with the public and other interested parties. In this regard, senior management,
under the guidance of the Municipal Manager will ensure that fraud and corruption will be
dealt with effectively and that the fraud and corruption strategy is reviewed and updated
annually. All employees and stakeholders will be made aware of anti - fraud and corruption
strategies through awareness campaigns and training.
Ethical conduct is based on a set of principles referred to as values or norms. The collective
ethical conduct of all Councillors and employees reflects the organisational ethical conduct.
In this regard, the highest standards of ethics are required by Councillors and employees
when fulfilling their duties and to the municipal code of conduct.
The Municipality subscribes to the eight Batho Pele Principles which are:
Consultation
Service Standards
Access
Courtesy
Information
Openness and Transparency
Redress
Value for Money
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6.2. Operational Strategies
6.2.1 Prevention strategy
Fraud and corruption can be prosecuted after the fact, but, first and foremost, it requires
prevention. The Municipality acknowledges the importance of utilizing its resources in the
most effective and efficient manner and as such recognises “prevention” as the fundamental
component of anti-corruption strategy. The prevention efforts should focus on identifying
controls to mitigate all three conditions;
Opportunity
Rationalization, and
Pressure
The component of prevention encompasses, creation of anti-fraud culture/behaviour, training
and awareness, policies and procedures, physical and information security, employee
vetting and risk management.
6.2.2. Fraud and Corruption risk assessment
The municipality, under the guidance of the Municipal Manager working together with MPAC
and the Audit Committee, as well as Provincial Treasury will ensure that fraud and corruption
risk assessments are conducted to identify potential fraud and corruption risk exposures.
The risk of fraud needs to be actively managed. This involves identifying the potential for
fraud and corruption and developing appropriate strategies to minimise the risk of it
occurring. The Municipality will conduct on annual basis fraud and corruption risk
assessments to identify potential fraud and corruption risk exposures to the institution. This
process will ensure that actions to address the identified fraud and corruption risk exposures
will be implemented to mitigate these exposures.
The above will be formulated into “Fraud Risk Assessment” and which will provide an
indication of how fraud and corruption manifested. A Fraud and Corruption Risk Register for
the prioritised risks will be developed as well as actions to mitigate these risks. Whilst
internal and external auditors may consider fraud risk, it is only one element in their audit
assessment model and it competes with other issues for attention. In addition, fraud
detection and prevention are not their primary reasons for conducting audits. Therefore,
management should not rely solely on audits as a mechanism for managing the risk of fraud.
6.2.3. Employee awareness
The primary function of training new and existing employees on the fraud strategy is a
fundamental process that inculcates the Municipality’s culture and philosophy of zero
tolerance on fraud and corruption to all employees. The Municipality will arrange workshops
to both internal and external stakeholders to create awareness of fraud and corruption, the
manifestations thereof and the plan in general. A further objective of this training is to
reinforce the expectations of the Municipality and administration of employees of the
Municipality with regard to their conduct and behaving ethically and with integrity. Processes
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and mechanisms to manage professional ethics are fundamental to the fight against fraud
and corruption. In line with the principles contained in the Public Sector Anti-Corruption
Strategy, the Municipality will pursue the following additional steps to communicate the
principles contained in the Code:
A copy of the Code will be circulated to all employees and included in the induction
packs for new employees.
Include relevant aspects of the Code in further awareness presentations, training
sessions and communication programmes to create awareness thereof amongst
employees and other stakeholders
Further objectives of this training will be the following:
Helping employees to understand the meaning of unethical behaviour (including
harassment in any form) in line with expectations of the Municipality.
Helping employees to understand issues involved in making ethical judgments; and
communicating the implications of unethical behaviour and its impact for individuals, the
workplace, professional relationships, the Municipality as whole and external
stakeholders including the public The development and constant review of the gift policy
to ensure that it adequately addresses both acceptance and offering of business
courtesies including gifts, by all employees of the Municipality.
The development of a more robust system for the declaration of private business
interests and actual or potential conflicts of interest by all employees and keeping of a
centralised record thereof will be considered
6.2.4 Municipality’s systems, policies, procedures, rules and regulations
The Municipality has a number of systems, policies, procedures, rules and regulations
designed to ensure compliance with government legislation. //Khara Hais Municipality has
identified a fraud and corruption risk in this area as being the lack of application, knowledge,
awareness, effective communication and training with regard to its prevailing prescripts. The
Municipality will develop clearly defined communication and training strategies to create
awareness of existing and new policies and procedures in order to ensure that all employees
are made aware of, and adequately trained in the implementation of policies and procedures
relevant to their duties and responsibilities, including -
The keeping of adequate records serving as proof that employees have been made aware of
the policies and procedures relevant to their duties; and
The development and distribution of a regular communiqué outlining the importance of
complying with policies and procedures and the implications for employees, for example–
The taking of corrective action against offenders not complying with policies and
procedures
The keeping of all policies and procedures accessible all the time to employees.
Policies and procedures to be updated continuously and made available to users.
//Khara Hais Municipality is committed to developing human resources systems, policies and
procedures, which will incorporate the fraud and corruption prevention practices detailed
below –
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The development of a system for transparent and merit-based hiring and promotion
practices with objective standards in order to reduce the risk of nepotism and favouritism,
both of which are damaging forms of fraud and corruption
The Municipality applies the resolutions of the Public Sector Collective Bargaining
Council, which enables employees who have been unfairly or falsely accused to seek
recourse. This is based on the recognition that aggrieved employees may become
malicious, thus increasing the risks of them committing fraud and corruption; and
The Municipality recognises that, despite on-going organisational and policy changes, for
example employment equity policies, matching of competence to the job is extremely
important.
As part of its approach to the management of human capital, the Municipality will
continue to pursue steps to ensure that competent people are being appointed
Management must be held accountable for complying with, and implementing, the
Municipality's systems, policies, procedures, rules and regulations and for preventing
fraud and corruption. This will be addressed in job descriptions, agreed work plans and
performance contracts.
The Municipality will also develop a system with clear guidelines for the placing of
prohibitions on individuals and restriction of entities found guilty of fraud and corruption
against it.
6.2.5. Physical and information security
Physical restrictions are the most important type of protective measures for safeguarding the
//Khara Hais Municipality’s assets, processes and data. Physical access to confidential
records and secured area should be properly controlled. Documentation and record retention
is to provide reasonable assurance that all information and transactions of value are
accurately recorded and retained. Records are to be maintained and controlled in
accordance with the Security Policy of the Municipality
The Municipality will conduct regular reviews of physical security in order to understand its
specific shortcomings in this area and ensure that, where necessary, security of offices is
upgraded in order to comply with the MISS Policy as developed by the National Intelligent
Agency (NIA).
Supplementary steps will be established to control access to archives, files, computer and
data systems. A comprehensive security policy should be developed and should among
other things cover control of; information computer systems, securing of official documents,
access control, physical search, contingency plan and key control.
6.2.6 Pre – employment screening (employee vetting)
Pre- employment screening will be carried for all appointments, with the involvement of
Security Management Unit, although the whole process is maintained by Human Resources.
Consideration should be given to the following areas;
Confirmation of ID and Addresses
Criminal records
Reference checks with pre employers (most recent)
Verification of formal qualification
Insolvency/ credit checks
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6.2.7 Security Clearance (Vetting)
Security screening/ vetting is required when a person is promoted, transferred or performs
general official duties that will give them access to classified information. The degree of
security clearance given to a person is determined by the content of and/or access to
classified information entailed by the post already occupied or to be occupied by a person.
Vetting will be carried out from the lowest level up to Senior Management for all staff
members and any stakeholders who should have access to classified information. The
security clearance period of validity ranges from 5 to 10 years; the categories that an
individual is analysed on in terms of security clearance level are as follows:
Top Secret
Secret, and
Confidential
6.2.8 Recruitment procedures
Recruitment will be conducted in accordance with Council recruitment policy. It will be a
transparent process and all appointments will be confirmed only after due recommendation.
Any person, involved in any decision-making process, who may have a conflict of interest,
must declare such a conflict in writing to the Municipal Manager and withdraw from any
further procedures.
6.2.9 Declaration of Secrecy
A declaration of secrecy form should be completed by anyone who applied for a municipal
position before he/she is appointed or during the appointment process.
6.2.10 Fraud and corruption prevention plan
For effective implementation of the Fraud and Corruption Strategy, a plan will be developed
with detailed procedures on how to implement the strategy. The actions/outputs set on the
plan are focused at mitigating the risk of fraud and corruption in the Municipality. The plan
will encompass at most the following;
Fraud Risk Assessment
Monitoring Process
Awareness
6.2.11 Internal controls
Internal controls are an integral part of the Municipality’s financial and non-financial policies
and procedures. An internal control consists of all the measures taken by the Municipality for
the purpose of -
a) Protecting its resources against waste, fraud, and inefficiency
b) Ensuring accuracy and reliability in accounting and operating data
c) Ensuring the efficiency of the Municipality’s processes and systems
d) Securing compliance with the policies of Municipality; and
e) Evaluating the level of performance in all units of Municipality
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Hereto are some of the internal controls that are crucial in execution of the activities.
(a) Segregation of duties
There are four general categories of duties or responsibilities which are examined when
segregation of duties is discussed: authorization, custody, record keeping and reconciliation.
In an ideal system, different employees would perform each of these four fraud prevention
plan/strategy major functions. In other words, no one person should have control of two or
more of these responsibilities. The more negotiable the asset, the greater the need for
proper segregation of duties, especially when dealing with cash and inventories. In instances
where duties cannot be fully segregated, mitigating or compensating controls must be
established.
Mitigating or compensating controls are additional procedures designed to reduce the risk of
errors or irregularities. For instance, if the record keeper also performs a reconciliation
process, a detailed review of the reconciliation could be performed and documented by a
supervisor to provide additional control over the assignment of incompatible functions.
Segregation of duties is more difficult to achieve in a centralized, computerized environment.
Compensating controls in that arena should include passwords, inquiry only access, logs,
dual authorization requirements, and documented reviews of input /output.
(b) Audit trail
The //Khara Hais Municipality will assign a competent team of its staff to look into the aspect
of audit trail on a regular basis. The task will comprise of looking into all functions starting
from capturing of information, updating of records of the Municipalities clients on the
database, capturing of any information that may lead to fraud and corrupt activities and up to
the payment stage. Not only should audit trail be limited to payments processing but all
areas across the Municipality.
(c) Monitoring
Internal control systems need to be monitored as a process that assesses the quality of the
system's performance over time. On-going monitoring occurs in the ordinary course of
operations, and includes regular management and supervisory activities, and other actions
personnel take in performing their duties that assess the quality of internal control system
performance.
The scope and frequency of separate evaluations depend primarily on an assessment of
risks and the effectiveness of on-going monitoring procedures. Internal control deficiencies
should be reported upstream, with serious matters reported immediately to management.
(d) Components of the control activity
Internal controls rely on the principle of checks and balances in the workplace. The following
components focus on the control activity - Personnel need to be competent and trustworthy,
with clearly established lines of authority and responsibility documented in written job
descriptions and procedures manuals.
Authorization procedures need to include a thorough review of supporting information to
verify the propriety and validity of transactions. Approval authority is to be commensurate
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with the nature and significance of the transactions and in compliance with relevant
regulations and legislation.
Segregation of duties reduces the likelihood of errors and irregularities. An individual is not
to have responsibility for more than one of the three transaction components: authorization,
custody, and record keeping. When the work of one employee is checked by another, and
when the responsibility for custody for assets is separate from the responsibility for
maintaining the records relating to those assets, there is appropriate segregation of duties.
This helps detect errors in a timely manner and deter improper activities; and at the same
time, it should be devised to prompt operational efficiency and allow for effective
communications.
6.3. Detection Strategies
The //Khara Hais Municipality has dedicated itself in detecting fraudulent and corrupt actions
that could harm the organization. It is within this premise that appropriate channels and
measures should be enhanced to ensure that detection of fraud is action based and
appropriate controls should be implemented. The Municipality is equally committed to
ensuring that appropriate measures are in place and taking all possible action so that any
fraud or fraudulent behaviour is detected at an early stage, is exposed and is subjected to
appropriate disciplinary and / or judicial action. A comprehensive and a detailed fraud
detection plan should be attached to this strategy in which it outlines the techniques the
//Khara Hais Municipality will use to detect most prevalent events of fraud and corruption.
The individual identified at the Institution will be responsible for developing detection
strategies, and will work closely with line management and the Internal Audit function for this
purpose. The Institution will embark on a number of initiatives to detect fraud and corruption
in the workplace.
6.3.1 Whistle blowing, reporting mechanisms and policies
//Khara Hais Municipality acknowledges the fact that the decision to report a concern can be
a difficult one to make, not least because of fear of reprisal from those responsible for the
irregularity. Those who often do “blow the whistle” end up being victimised and intimidated.
The Municipality will not tolerate harassment or victimisation and will take action to protect
staff when they raise a concern in good faith. Any act of harassment or victimisation should
be reported to the Head of Department. This does not mean that if a staff member is already
subject of disciplinary or other actions will be halted as a result of their whistle blowing. For
this reason, the Municipality will adopt a Whistle Blowing Policy setting out the detailed
procedure which must be followed in order to report any incidents of fraud and / or
corruption. This policy will be designed to comply with the provisions of the Protected
Disclosures Act.
Any suspicion of fraud and corruption will be treated seriously and will be reviewed,
analysed, and if warranted, investigated. If an employee becomes aware of a suspected
fraud, corruption or any irregularity or unethical behaviour, such issues should be reported in
terms of a Whistle Blowing Policy.
The fundamental objective of the Protected Disclosure Act, No 26 of 2000 is to protect
workers from detrimental treatment or victimisation from their employer if in the public
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interest; they blow the whistle on wrongdoing. An employee who reports suspected fraud
and corruption may remain anonymous should he / she so desire. Information received as a
protected disclosure is strictly confidential, and includes the identity of the person making the
disclosure, nature of the disclosure and also the identity of the person or persons against
whom the disclosure has been made. No person will suffer any penalty or retribution for
good faith reporting of any suspected or actual incident of fraud and corruption which
occurred within the Municipality.
All managers should discourage employees or other persons from making allegations, which
are false and made with malicious intentions. Where such allegations are discovered, a
person who made the allegations must be subjected to firm disciplinary, or other appropriate
action.
6.3.2 Reporting mechanism
Any employee who has knowledge of an occurrence of irregular conduct, or has reason to
suspect that a case of fraud or corruption has occurred has to immediately notify his / her
supervisor, any senior manager, Should employees wish to report allegations of fraud and
corruption anonymously, the following reporting mechanisms are available:
National Anti-Corruption hotline number 0800 701 701
Presidential hotline number 17737
//Khara Hais Municipality 054 - 3387000
The employee shall not discuss the matter with anyone other than his / her supervisor, any
senior management member. Employees who knowingly make false allegations will be
subject to discipline or legal proceedings depending on the seriousness of allegations. All
managers are also responsible for reporting all incidents and allegations of fraud and
corruption to the Municipal Manager. The Municipal Manager will initiate an investigation into
the matter.
The Municipal Manager is required to ensure that losses or damages suffered by the
Municipality as a result of all reported acts committed or omitted by an employee or any
other person are recovered from such an employee or other person if he or she is found to
be liable for such losses.
6.3.3 Immediate action on crime being discovered or suspected
The recommended sequence of events on the discovery of a crime or suspected crime
should be:
a) An immediate report should be made to the specific Head of Department, who should in
turn notify the Municipal Manager and Human Resources.
b) Human Resources should take immediate steps to preserve all possible evidence and
secure assets at risk.
c) Appointment of an investigation officer by the Municipal Manager.
d) The case investigator will need to decide on the immediate subsequent action.
Irrespective of the nature and seriousness of the crime this action may include
depending the nature of the suspected crime: -
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Notifying the South African Police Services;
Notifying the Office of the Auditor-General;
Take the necessary steps to secure the assets at risk;
The removal of the suspect from a position of authority and the withdrawal of signing
powers, revoking of the staff members access to the municipality’s computer
systems;
Securing the contents of the suspects office, personal computer, diary and files,
including all personal documents on the premises;
Changing passwords and access codes as well as securing accounting and other
records;
Doing a preliminary assessment of the following issues:-
a) The possible need for civil recovery in terms of section 300 of the Criminal Procedure Act
(Act 51 of 1977);
b) The possible requirement for a sequestration or anti-dissipation interdict order from the
courts;
c) The registration of a likely insurance claim;
d) The specialist investigative resources which may be required;
e) And a recovery in terms of Section 37D of the Pensions Act.
6.3.4 Investigation within the Municipality
The investigation officer as appointed by the Municipal Manager will conduct a preliminary
investigation before the Municipal Manager will decides to report the matter to the South
African Police Service, depending on the seriousness, impact on the organization and nature
of crime.
6.3.5 Specialists
If needed and approved by the Council or Municipal Manager, the assistance of specialists
will often be required during the course of investigations due to certain expertise required or
a lack of capacity within the municipality. The specialist's primary function will be to assist
the investigation team. Some examples of experts include: -
Computer Expert
These experts should be prepared to secure the computer evidence (either on a network or
a PC), in such a manner that it will be acceptable in a court of law. The computer expert
should:
Have a real understanding of the roles that computers can play in the commission of
a crime;
Be able to provide clear simple testimony of what they can prove to be a fact;
Have a high professional reputation as well as a professional approach;
Be trustworthy and able to work as part of a team;
Be articulate, in terms of being able to explain technical computer matters to laymen;
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 16
The expert must be an articulate and credible witness who will be able to establish the
accuracy of the data processing evidence being presented in a disciplinary hearing or a
court of law.
Legal Expert
This person should be trained and know what is required for both civil legal recoveries and
criminal prosecution. The legal expert will also be required to assist in supplying the
investigating team with guidance as to where to focus the investigation, drafting of charge
sheets and the preparation of witnesses.
Industrial Relations Consultant
This person should be warned that he/she would have to (on occasions) initiate such actions
as suspension, internal disciplinary hearings and provide advice on the organization's
approach to the recovery of money under the auspices of the appropriate section of the
Basic Conditions of Employment Act as well as on the Pension Funds Act No. 24 of 19.
6.3.6 Anonymous Allegations
//Khara Hais Municipality encourages staff to put their names to allegations. Concerns
expressed anonymously are difficult to investigate; nevertheless they will be followed up at
the discretion of //Khara Hais Municipality. This discretion will be applied by taking into
account the following:
Seriousness of the issue raised;
Credibility of the concern; and
Likelihood of confirming the allegation.
6.4. Internal control reviews and data analysis
Reviewing controls on a regular basis could be a fundamental detection mechanism and
also perform random assessment of transactions and processes. The Security Management
Unit should constantly review the internal controls and analyse and interrogate data to
determine unfamiliar trends and investigate further. This could be a very useful approach of
detecting fraudulent actions. Internal controls are the first line of defence against fraud and
corruption. While internal controls may not fully protect the municipality against fraud and
corruption, they are essential elements in the overall Anti-Fraud and Corruption Strategy.
The Internal Audit function will be responsible for implementing an internal audit program
which will incorporate steps to evaluate adherence to internal controls. All areas of
operations require internal controls, for example:
Physical controls (security of assets);
Authorisation controls (approval of expenditure in terms of supply chain management
delegations);
Supervisory controls (supervising issues on a daily basis);
Analysis of data;
Annual financial statements;
Reconciliation of bank statements.
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 17
6.4.1 Internal Audit
Internal Audit must report directly to the Accounting Officer and Audit Committee. The
function must be independent of activities that are audited, with no limitation on its access to
information. Although the primary responsibilities of the Internal Audit activity are not to
detect fraud, internal audit to be mindful of fraud and assist management in detecting fraud
through their audit process. Internal audit will audit the case management on an annual
basis.
A robust Internal Audit plan, which focuses on the prevalent high fraud and corruption risks,
serves as an effective preventative measure. The Internal Audit function will compile such a
plan on an annual basis.
7. Response Strategies
7.1. Investigating fraud and corruption
As a public service institution, the Municipality is committed to ensuring the highest possible
standards in the conduct of its affairs. The //Khara Hais Municipality is equally committed to
ensuring that appropriate measures are in place and taking all possible action so that any
fraud or fraudulent behaviour is detected at an early stage, is exposed and is subjected to
appropriate disciplinary and / or judicial action.
7.1.2. Members of the public
The Council, management and staff members of //Khara Hais Municipality encourages that
members of the public or providers of goods and/or services who suspect fraud and
corruption to contact any member of management, the Municipal Manager, the Mayor or/and
telephone numbers stated in paragraph if they wish to remain anonymous.
7.1.3 Reporting procedures and resolution of reported incidents
It is the responsibility of all employees within //Khara Hais Municipality to report all incidents
of fraud, corruption, theft, maladministration and other suspected irregularities of this nature
to his / her manager.
It is the responsibility of all employees to immediately report all allegations or incidents of
fraud and corruption to their immediate manager. Should an employee be concerned that the
manager is involved; the report can be made to any other member of management, the
Municipal Manager and/or the Chairperson of the Audit Committee.
Suspected cases of any fraud, corruption or maladministration should be reported
immediately after the discovery of such an incident or within 24 hours of the discovery of
such an incident.
7.1.4. Confidentiality
In accordance with Protected Disclosures Act No.26, of 2000, no employee may be
subjected to an occupational detriment by his/her employer on account or partly on account,
of having made a protected disclosure.
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 18
All information relating to fraud and corruption that is received and investigated will be
treated confidentially. The progression of investigations will be handled in a confidential
manner and will not be disclosed or discussed with any person(s) other than those who have
a legitimate right to such information.
This is important in order to avoid harming the reputations of suspected persons who are
subsequently found innocent of wrongful conduct. No person is authorized to supply any
information with regard to allegations or incidents of fraud and corruption to the media
without the express permission of the Director General.
7.1.5. Legal recourse for anyone affected under protected disclosure
Any employee who has been adversely affected by the disclosure of protected information
may:
Approach any court having jurisdiction, including the Labour Court established by
Section 115 of the Labour Relations Act, 1995 (Act No. 66 of 1995), for appropriate relief
Pursue any other process allowed or prescribed by law
7.1.6 Publication of sanctions
The Municipal Manager will decide, in consultation with appropriate senior managers,
whether any information relating to corrective actions taken or sanctions imposed, regarding
incidents of fraud and corruption should be brought to the direct attention of any person or
made public through any other means.
8. Maintenance Strategies
8.1 Review of the effectiveness and updating of the fraud and corruption strategy and
plan
The detailed procedures on the document should be monitored and reviewed by responsible
parties as follows; review to be done:
At least on an annual basis or
When legislation, systems or procedures have changed to such an extent that a review
and amendments to this document will be necessary
Monitoring to be done throughout the year.
Updated and accurate control matrix maintained
9. Resolutions
9.1 Disciplinary codes and procedures
The //Khara Hais Municipality recognizes the fact that the consistent and efficient application
of disciplinary measures is an integral component of effective fraud and corruption
prevention. The disciplinary code and procedures prescribes appropriate steps to be taken
to resolve disciplinary matters. The Directorate: Human Resource Management supports the
//Khara Hais Municipality in instituting and completing disciplinary action for cases of fraud
and corruption where an official is party to the crime.
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 19
The responsible manager, with the assistance of Human Resources Division must also
ensure that the following steps are taken with regard to financial misconduct in line with the
provisions of the Treasury Regulations and MFMA:
a) Ensuring that disciplinary proceedings are carried out in accordance with the relevant
prescripts
b) Ensuring that disciplinary proceedings are instituted within 30 days
c) Advising the executive authority, the Department of Public Service and Administration
and the Public Service Commission on the outcome of disciplinary proceedings
d) Annually submitting to the National Treasury and Auditor-General a schedule of:
I. The outcome of any disciplinary hearings and/or criminal charges
II. The names and ranks of officials involved; and
III. The sanctions and any further actions taken against these officials
9.2 Referring cases to other agencies
Any fraud and corruption committed by an employee or any other person will be pursued by
thorough investigation and to the full extent of the law, including (where appropriate)
consideration of -
Initiating criminal prosecution by reporting the matter to the SAPS or any other relevant
law enforcement agency
Any other appropriate and legal remedy available
9.3. Reporting cases to the Department of Public Service Administration (DPSA)
//Khara Hais Municipality will provide the DPSA with the following minimum information at
the end of each financial year Number of allegations of corruption received and corruption
cases detected per defined categories as defined in the Prevention and Combating of
Corrupt Activities Act, 2004 and service delivery area
a) Number of allegations and cases referred:
I. Handled in terms of disciplinary procedure
II. Referred to law enforcement agency or other body
III. Not investigated for disciplinary purposes or not referred
IV. Description of corruption risk areas
b) Report on the performance of its minimum anti-corruption capacity as part of its
annual report
9.4. Improving controls and prevention measures
In the event of fraud or corruption been exposed, it is essential that internal controls and
other prevention measures must be appraised in order to determine whether a specific
internal control factor has contributed to the incident of fraud or corruption occurring.
If weaknesses in terms of internal controls or prevention measures are discovered during
investigation, then such findings should be duly reported and recommendations forwarded to
the Risk Management Committee through the appropriate channels.
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 20
Senior or line function managers should identify and report any loopholes or shortcomings in
their area of operation.
10. Oversight structures
All oversight structures should play their role in ensuring that the Fraud Prevention Plan is
implemented and monitored.
11. Fraud and corruption case database
The purpose of the fraud and corruption database is to collate information from participating
jurisdictions to allow the Municipality to be a step ahead of the fraudsters. Fraud
investigators will be kept up to date on emerging trends and new techniques in all areas.
The Municipality through the Risk Management Unit must establish a central database to
track criminal activity within the Municipality’s operations. //Khara Hais Municipality should
establish links with participating jurisdictions that are involved in fighting fraud and
corruption.
12. Application of the Prevention Controls and Detective Mechanism
In all instances where incidents of fraud, corruption, theft, maladministration and other
similar irregularities of this nature take place, all Managers are required to immediately
review the controls which have been breached in order to prevent similar irregularities from
taking place in future, within a period of 48 hours after the occurrence of the initial incident.
The Head of the Internal Audit Unit may be contacted for assistance in this regard.
In compliance with the MFMA, Fraud prevention Plans (FPP) will be developed and
implemented by all heads of department.
13. Monitoring, Oversight and Review
The parties responsible for the monitoring of the detailed procedures in this document are:
Risk Management Committee
Risk Management Function
Department of Cooperative Governance, Human Settlement and Traditional Affairs
(COGHSTA) - Fraud Unit
The above mentioned parties must monitor and oversee the detailed policy and procedure
on this document on:
At least on an annual basis or
When legislation, system or procedure have changed to such an extent that a review and
amendments to this document will be necessary.
14. Specific provisions
This policy document should always be updated should there be any changes or
amendments
Formal communication of any changes in the policy, procedures and processes is
required.
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 21
Training will be required where there are major changes in responsibility, skills,
procedures or system
15. Administration
The custodian of this policy is the Accounting Officer who supported in its
implementation by all Heads of Department.
The Accounting Officer is responsible for the administration, revision, interpretation and
application of this policy.
RECOMMENDED BY:
…………………………… ……….……….
CHAIRPERSON OF RMC DATE
APPROVED BY
…………………………... …………………
ACCOUNTING OFFICER DATE
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 22
16. GLOSSARY OF TERMS
FORMS OF CORRUPTION
Corruption takes various forms in the public service and elsewhere in society. The following
are examples of different types of corruption.
BRIBERY - involves the promise, offering or giving of a benefit that improperly affects the
actions or decisions of public servants.
EMBEZZELEMENT -This involves theft of resources by persons who control such
resources.
FRAUD - Any conduct or behaviour of which a dishonest representation and/or appropriation
forms an element.
EXTOTION - Coercion of a person or entity to provide a benefit to a public servant, another
person or an entity, in exchange for acting (or failing to act) in a particular manner.
ABUSE OF POWER - The use by a public servant of his or her vested authority to
improperly benefit another public servant, person or entity (or using vested authority to
improperly discriminate against another public servant, person or entity).
CONFLICT OF INTEREST - The failure by a public servant to act or to consciously fail to act
on a matter where the public servant has an interest or another person or entity that has
some form of relationship with the public servant has an interest.
ABUSE OF PRIVILEGED INFROMATION - This involves the use, by a public servant of
privileged information and knowledge that a public servant possesses as a result of his/ her
office to provide unfair advantage to another person or entity to obtain a benefit.
FAVOURITISM - The provision of services or resources according to personal affiliation (for
example cultural or religious) of a public servant.
NEPOTISIM - A public servant ensuring that family members are appointed to public service
positions or that family members receive contracts from the state is regarded as nepotism.
TENDERPRENEUR - individuals who enrich themselves through corrupting the awarding of
government tender contracts, mostly based on personal connections and corrupt
relationships - although outright bribery might also take place - This is often accompanied by
overcharging and shoddy workmanship.
FRONTING - abuse of the rules governing Black Economic Empowerment (BEE), where
qualifying persons are given a seat on the Board of Directors of a company while having no
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 23
decision-making power in the company, in order to qualify the company for government
contracts in terms of BEE.
INFLUENCE – PEDDLING - a person selling his/her influence over the decision making
process to benefit a third party.
PATRONAGE - favoring supporters, for example with government employment. This may be
legitimate, as when a newly elected government changes the top officials in the
administration in order to effectively implement its policy. It can be seen as corruption if this
means that incompetent persons, as a payment for supporting the regime, are selected
before more able ones.
CRONYISM – benefiting of personal friends of an official as a form of illegitimate private
gain.
KICKBACK - an official's share of misappropriated funds allocated from his or her
organization to an organization involved in corrupt bidding
UNHOLY ALLIANCE - a coalition among seemingly antagonistic groups for ad hoc or
hidden gain
These manifestations are by no means exhaustive as corruption appears in many
forms and it is virtually impossible to list all of these.
GLOSSARY INTERPRETATION
BATHO PELE PRINCIPLES Means an initiative from the DPSA to get public servants to be
service orientated, to strive for excellence in service delivery and to commit to continuous
service delivery improvement. It is a simple and transparent mechanism, which allows
citizens to hold public servants accountable for the level of services they deliver
CODE OF CONDUCT Means a set of rules outlining the responsibilities of or proper
practices for an individual or organization
FRAUD PREVENTION PLAN Means a plan that all organisation’s should have in place that
integrates the processes, policies and resources of the business to minimise the risks
inherent to fraud and economic crime
MUNICIPAL FINANCE MANAGEMENT ACT – MFMA Means an Act that was established
to regulate financial management in the local government; to ensure that all revenue,
expenditure, assets and liabilities of that government are managed efficiently and effectively;
to provide for the responsibilities of persons entrusted with financial management in that
government and to provide for matters connected therewith
PREVENTION AND COMBATING OF CORRUPT ACTIVITIES ACT OF 2004 Means an Act
which provides for the strengthening of measure to prevent and combat corruption and
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 24
corrupt activities, to provide for the offence of corruption and offences relating to corrupt
activities, to provide for investigative measures in respect of corruption and related activities,
to provide for the establishment and endorsement of a Register to place certain restrictions
on persons and enterprises convicted of corrupt activities relating to tenders and contracts,
to place a duty on certain persons holding a position of authority to report certain corrupt
transactions, to provide for extraterritorial jurisdiction in respect of the offences of corruption
and offences relating to corrupt activities
PROTECTED DISCLOSURES ACT NO 26 OF 2000 Means an Act which makes provision
for procedures in terms of which employees in both the private and public sector may
disclose information regarding unlawful or irregular conduct by their employers or other
employees in the employ of their employers, to provide for the protection of employees who
make a disclosure which is protected in terms of the Act and to provide for matters
connected therewith
PUBLIC SECTOR ANTICORRUPTION STRATEGY Means an anti-corruption strategy
which had been developed for the Public Service to give effect to the expressed commitment
of Government to fight corruption in the Public Service. In accordance with the resolution of
the National Anti-Corruption Summit the strategy represents a further step toward
Government’s contribution towards establishing a National Anti-Corruption Strategy for
South Africa
EMPLOYEE Means a person in the service of the //Khara Hais Municipality under any
contract or hire, express or implied, oral or written, where the employer has the power or
right to control and direct the employee in the material details of how the work is to be
performed
RISK MANAGEMENT UNIT Means a Unit within the Internal Audit and Risk Management
Division of //Khara Hais municipality to ensure that its risk management needs and activities
are developed, implemented and monitored for on-going effectiveness and efficiency
WHISTLE BLOWING Means an employee or external person who has inside knowledge of
illegal / corrupt activities occurring within the organization and reports these to an
authoritative person / public
CORRUPTION in its wider meaning, and as referred to in this document, includes any
conduct or behaviour where a person accepts, agrees or offers any gratification for him/her
or for another person where the purpose is to act dishonestly or illegally. Such behaviour
also includes the misuse of material or information, abuse of a position of authority or a
breach of trust or violation of duty.
17. Addendum
Summary of Fraud Prevention Plan
Outcome/Output Activity Indicator Responsibility Due date
The municipality
knows the level of
Conduct a Fraud Risk
Assessment for the
Fraud risk register Risk Management
Unit
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 25
risk //Khara Hais
Municipality
Establish the main
risks within the
municipality
Risk Monitoring-
monitoring of the
implementation (fraud
risks)
Quarterly progress
reports
Risk Management
Unit
Reduced fraud
accounts due to
proper
implementation of
recommendations
by HRM
Monitoring of
subsequent
processes of Fraud
recoveries on Fraud
accounts
Risk monitoring report Risk Management
Unit
HRM
On going
Regular
arrangement and
facilitation of
awareness
workshops to
external and
internal
stakeholders
Regular
communiqué and
training outlining
the importance of
complying with
policies and
procedures
Conduct Fraud and
corruption awareness
workshops
Circulate manuals
and publications
Communication and
training on existing
and new policies and
procedures
Improved compliance to
policies and procedures
Communication and
training compliance
report on policies and
procedures
Risk Management
Unit
Communication
Training and
Development
All sections
Fraud risk appetite
& tolerance level
set and aligned to
the strategic
objectives of the
municipality
Engage management
to set the fraud risk
appetite and
tolerance levels
Risk appetite table Risk Management
Unit
Employees with
Private businesses
declare
Declaration of private
business interests
Centralised record
keeping of
declarations
Register for Private
Business Interests
Human Resource
Management
Supply Chain
Management
Reduce nepotism,
favouritism and
Development of
transparent system
Recruitment and
selection report.
Human Resource
Management
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 26
comply with
Recruitment and
selection policy
for selection and
recruitment
Management
accountability of
compliance
Development of job
descriptions,
performance
contracts and work
plans
Performance
Management
Human Resource
Management
Managers
Records/
documents
secured
confidential as per
the security policy.
Access control to
confidential records
Regular reviews of
physical security
Records management
and physical security
report.
Security
management
Positive results of
employment
screening on all
appointments
Conduct pre-
employment
screening to all
appointments
Register of all screening
results
Human Resource
Management
Security Section
On-going
Personnel security
competence
Conduct Security
clearance/ vetting for
all personnel from the
lowest level up to
Senior Management
with access to
confidential
Information
Security clearances /
vetting results
Human Resource
Management
Security Section
On-going
Protection of
classified
information and/or
interest of the
Municipality
Declaration of
secrecy forms
completed by all
personnel with
access to confidential
Information
Access register of all
personnel with access to
confidential information
Human Resource
Management
Security Section
On-going
Segregation of
duties
Categories of duties
or responsibilities
separated amongst
employees
Good control All business units On-going
independent
review by Internal
Audit
Improvement of
controls on
identified as red
flags
Monitoring of audit
trail on regular basis
Audit trail monitoring
report
On-going
ANTI-FRAUD AND CORRUPTION STRATEGY AND PREVENTION PLAN Page 27
Internal control
systems monitoring
Develop monitoring
processes to assess
quality of systems
performance over a
period of time
Constant internal
control reviews and
random assessments
of transactions and
process
Quality Systems
assessment and
monitoring registers
Risk Management On-going
Safe and
responsible
reporting of fraud
and corruption
Reporting of
suspected fraud and
corruption activity or
irregular conduct,
through the fraud
hotline and email
Management hotline
reports
Internal and
external
stakeholders
Risk Management
Unit
On-going
Disclosure of cases
to DPSA
Submission of
information on cases
at the end of each
financial year
Annually reports
accurately reflecting
cases
Human Resource
Management
Updated database
of criminal activities
within the
Municipality
Establish central
database on fraud
and corruption
activities
Fraud and corruption
trend analysis
Risk Management
unit
On-going